When named plaintiffs and defendants in a class action agree to a settlement, they must obtain the court’s preliminary approval of the proposed class action settlement. Thereafter, class members are notified of the proposed settlement and given an opportunity to file objections, which the court will consider before determining whether finally to approve the proposed settlement. The Second Circuit has stated that class members who object to a proposed settlement serve an important role in “preventing collusive or otherwise unfavorable settlements.” White v. Auerbach, 500 F.2d 822, 828 (2d Cir. 1974).

Nevertheless, in recent years, certain class action objectors have sought to file frivolous objections and appeals concerning proposed settlements to obtain personal payments in exchange for voluntarily dismissing their objections. The Seventh Circuit has recently described this practice, which delays the resolution of class actions and depletes settlement resources, as “objector blackmail.” Pearson v. Target, 893 F.3d 980, 982 (7th Cir. 2018).